Subject: File No. S7-16-98
 
Date:    8/18/98 9:21 AM
     
     
August 18, 1998
     
Mr. Johnathan  G. Katz, Secretary
Securities and Exchange Commission
450 5th Street, N.W.
Washington, D.C.  20549-6009
     
re:  File No. S7-16-98, Proposed Rule Defining Improper Professional Conduct
     
Dear Mr. Katz:
     
I am writing to add my voice to those of others in the AICPA who disagree 
with the SEC's proposed rule defining improper professional conduct.
     
In his August 1998 letter to the AICPA's Business and Industry Executive 
Committee and SECPS Executive Committee, Mr. Richard I. Miller, AICPA 
General Counsel and Secretary, lists six reasons I believe are compelling as 
to why the language of the proposed rule is unsuitable.
     
I hope the SEC will very carefully consider the well-reasoned objections 
articulated by Mr. Miller and be persuaded to adopt instead the standard 
proposed by the AICPA in its earlier petition.
     
Sincerely,
     
John M. Lorentz
Controller
20th Century Industries
6301 Owensmouth Avenue
Woodland Hills, CA 91367
818-704-3797